EU Digital Product Passport · ESPR
The EU's Digital Product Passport, required under the Ecodesign for Sustainable Products Regulation (ESPR), rolls out one product category at a time rather than on a single date. Batteries go first, mandatory 18 February 2027. The central EU registry that market surveillance authorities check against activates earlier, on 19 July 2026. Electronics and ICT aren't in a finalised delegated act yet, but the Commission's own Working Plan already gives an indicative window — and most companies aren't building toward it.
Last updated 31 August 2026
The European Commission activates the central DPP registration infrastructure on 19 July 2026 — the system market surveillance authorities use to automatically verify whether a product has a valid, registered passport. That's not a compliance deadline in itself, it's the plumbing going live ahead of the first category obligation. Batteries are the first product group actually required to carry a working Digital Product Passport, from 18 February 2027, with other categories — textiles, electronics, furniture, tyres, construction products — following in delegated acts at short intervals after that.
Source: Informatica; PassportCraft.
Unlike batteries, electrical and electronic equipment isn't named as a standalone priority product group in the first ESPR Working Plan with its own single delegated act and date. Instead it's addressed through horizontal work streams: repairability requirements, and recycled-content/recyclability requirements, both of which apply across electronics rather than to one narrow product type. The Commission's own indicative timeline puts electronics repairability requirements around 2027 and recycled-content/recyclability requirements around 2029. Those dates can move as each delegated act is actually finalised and adopted — but the categories, the mechanism, and the rough window are already public, which is enough to start scoping now rather than waiting for a fixed date to force the issue.
Source: MyProductPassport; Narravero.
KPMG's European Digital Product Passport Readiness Survey (fieldwork Sep-Dec 2025, published February 2026, more than 70 firms spanning sectors including textiles and metals) found only 19% of respondents rate themselves "well-prepared" — with assigned roles and a comprehensive, executive-backed roadmap in place — leaving 81% without one. That gap matters because implementation isn't fast once you start: typical build time runs six to twelve months, and sourcing supply-chain data is the critical path, not the technical build. For anyone still without a plan, the runway between the registry opening and a category's mandatory date is already shorter than the implementation time it takes to fill it.
The Digital Product Passport (DPP) is a mandatory digital record of a product's materials, sourcing, repairability and environmental data, required under the Ecodesign for Sustainable Products Regulation (ESPR). It's accessible via a data carrier (typically a QR code) on the product and is checked against a central EU registry by market surveillance authorities and, for some data, consumers.
The DPP applies product category by product category as ESPR delegated acts are adopted, not on one single date. Batteries are first: the digital Battery Passport becomes mandatory on 18 February 2027. The EU's central DPP registry infrastructure activates earlier, on 19 July 2026, so market surveillance authorities can start verifying registered passports as soon as the first category's deadline lands. Electronics and ICT are not yet in a finalised delegated act, but the Commission's ESPR Working Plan gives an indicative 2027 timeline for electrical/electronic equipment repairability requirements and 2029 for recycled-content and recyclability requirements.
No, mostly not. KPMG's European Digital Product Passport Readiness Survey (fieldwork Sep-Dec 2025, published February 2026, 70+ firms including textiles and metals sectors) found only 19% of respondents rate themselves "well-prepared" — with assigned roles and a comprehensive, executive-backed roadmap in place — meaning 81% do not yet have one. Implementation typically takes six to twelve months once a company starts, and supply-chain data sourcing is the critical path — which is longer than the gap between the registry going live and the first category deadline for anyone starting late.
Not yet under a finalised delegated act, but it is coming and the direction is set. ICT products and other electronics are addressed through ESPR's horizontal work streams on repairability and on recycled content/recyclability of electrical and electronic equipment, rather than as a single named priority product group in the first Working Plan. The Commission's own indicative timeline puts electronics repairability requirements around 2027 and recycled-content/recyclability requirements around 2029 — timing that can move as each delegated act is finalised, but the direction and rough window are already public.
Batteries already have a fixed date; electronics has a direction and a rough window but not yet a fixed one. Both need the same groundwork: knowing which delegated act actually covers your product category, what data your passport needs to carry, and whether your supply chain can currently produce it. We scope that gap now, category by category, rather than waiting for a finalised date to force a rushed build.
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